POLICIES

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Longo's Privacy Commitment

Updated: August 13, 2021

Longo Brothers Fruit Markets Inc., including its e-commerce business Grocery Gateway, and its direct and indirect subsidiaries (wholly or partially owned), parents, and affiliates, including each of their owned, operated or affiliated banners, brands or divisions, (collectively, “Longo’s”, “we”, “us” and “our”) respect the privacy of each customer and prospective customer (“Guest” or “you”). The term “Guest” also includes persons who visit our websites, make online purchases, use our mobile apps, subscribe to our e-mail communications, enter into one of our contests, correspond or communicate with us, have enrolled, or are applying for enrolment, in any rewards or similar program of which Longo’s is a sponsor or participant, including without limitation our “Thank You Rewards ” program (each of which is referred to as a “Program”). Longo’s is committed to protecting all personal information collected from Guests.

This Longo’s Privacy Commitment (the “Privacy Commitment”) is intended to assist Guests in understanding the purposes for collection by Longo’s of personal information and how personal information is used, protected, stored and disclosed by Longo’s and its employees, agents, partners participating in joint marketing and promotional programs, Program(s) or other arrangements from time to time (“Partners”), and any other authorized third party who may receive Guests’ personal information to assist us in serving our Guests.

This Privacy Commitment contains important information on our commitment to the protection of your Personal Information, including:

 

  • What we mean by "Personal Information"
  • The purposes for which we collect and use your Personal Information, and when we collect it
  • The Internet technologies we may use to collect and process your Personal Information
  • The way we may engage in Interest-Based Advertising
  • With whom we may share your Personal Information, and the location in which your Personal Information may be stored
  • The manner and location in which we may retain your Personal Information
  • The ways that we protect your Personal Information
  • How to access, correct or update your Personal Information
  • How to contact us about privacy issues

By doing business with us, visiting our websites, using our mobile apps, subscribing to our e-mail communications, entering one of our contests, enrolling or applying for enrollment in a participating Program or otherwise corresponding or communicating with us, you agree to Longo’s collecting, using and disclosing your personal information in accordance with this Privacy Commitment.

This Privacy Commitment complies with all applicable federal and provincial privacy legislation.

 

Personal Information

Personal information is any information about an identifiable individual, including any information that, alone or in combination with other information, could be used to identify an individual. Personal Information includes, but is not limited to a Guest’s name, home address, email address, telephone number, date of birth and purchasing information, (in this Privacy Commitment referred to as “Personal Information”).

Personal information does not include aggregated information, or any personal information that has been de-identified through the removal of potentially identifying details, such that the data may not be identified with a particular individual.

 

Purposes

Longo’s generally collects, uses and discloses Personal Information to operate our businesses and to administer our Programs, including for the following purposes (the “Purposes”):

a) to communicate with Guests regarding orders, purchases or any concerns or queries the Guest may have;

b) to communicate with Guests regarding any changes to this Privacy Commitment or to Programs and their operation, where applicable;

c) with consent, or as permitted by law, to communicate with Guests regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as but not limited to products and services under the Programs or available through Partners that may be of interest to the Guests;

d) to ensure Guests are appropriately awarded points or their equivalent in accordance with the rules of the applicable Program and receive reward redemptions in accordance with applicable Program Rules and that rewards records are appropriately maintained;

e) to process information regarding Guest orders, purchases and the collection and redemption of points and rewards;

f) to provide services, rewards, products and benefits to Guests and to enable them to participate in contests;

g) to understand and analyze the interests, needs and preferences of Guests;

h) to develop, enhance, market, recommend and/or provide products and services to meet the needs and interests of Guests and potential Guests;

i) for marketing and analytics purposes, including to display targeted advertising as set out in the Interest-Based Advertising section below;

j) to verify Guests’ identity, when required or desirable for transactional purposes, so as to reduce fraud or errors in transaction processing;

k) to comply with applicable legislation and regulatory requirements; and

l) for investigation and law enforcement purposes.

Longo’s does not collect Personal Information from Guests other than for the purposes identified in this Privacy Commitment, unless further consent is obtained, or where otherwise required or permitted by law.

Longo’s collects Personal Information from Guests in several ways, including but not limited to, at the time of enrolment in a Program, when subscribing for e-mail communications, when visiting one of our stores, when a purchase, return, inquiry or Program redemption is made by a Guest both in-store and online, through Partners, through online use of any of our websites or Program website, through use of one of our mobile apps, through Guest interaction with customer services offered by Longo’s and/or Program(s), through surveys or questionnaires or other research conducted by or on behalf of Longo’s or a Partner and through contests entered by a Customer.

We also collect Personal Information from:

(a) individuals when they apply for employment through a Longo’s website, in person at a store, or otherwise. We use this Personal Information solely for the purpose of processing and responding to such applications.

In this Privacy Commitment, references to “Guests” also apply to the individuals referred to in paragraph (a) above with any changes necessary in the circumstances.

 

Sharing

From time to time, we may share your Personal Information with third party service providers that we have engaged to perform services on our behalf, based on our instructions, such as advertising agencies, marketing agents, data processing and storage companies or organizations which provide administrative and support services to Longo’s. We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the third-party service provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide Longo’s with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at the addresses provided under “Contact Us”.

From time to time we may disclose to third parties aggregated or de-identified data, which does not contain Personal Information or other information regarding identifiable individuals.

Longo’s may share or transfer your Personal Information where reasonably required in the context of a sale, merger, reorganization or amalgamation of all or part of our business or the insurance of securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your Personal Information, as obtained from Longo’s only for the purposes set out this Privacy Commitment, unless your further consent is obtained.

Longo’s may also share your Personal Information with third parties as required or permitted by law, such as:

  • to government bodies and law enforcement agencies, pursuant to warrant, order or statutory requirement;
  • in connection with any legal proceedings or prospective legal proceedings involving Longo’s;
  • to otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention and reducing credit risk), as permitted by law.

Longo’s does not otherwise share, give, rent or sell your Personal Information to any third parties, unless your additional consent to do so is obtained. Longo’s will take reasonable measures to ensure that the Personal Information we collect is accurate and complete. We will update our records regarding Guests based on the information communicated directly or indirectly to us by Guests or Partners. In order to ensure that our records are as complete and accurate as possible, you are responsible for informing Longo’s of any relevant changes to your Personal Information, such as a change of name or a change of address or other contact details.

Our websites may contain links to other websites. We are not responsible for the privacy practices or the content of sites (other than our own sites) to which we provide links. You should check the privacy policies of these other websites before choosing to provide any Personal Information to such third-party sites.

 

Cookies and Tracking Technologies

When you visit one of our websites or use one of our apps, we may use certain automated tools to provide you with a more personalized browsing experience, better understand your needs, provide you with content that is most relevant to you and monitor trends respecting the usage of our site and apps.

In general, you can visit one of our websites without telling us who you are or submitting any Personal Information. However, through log files and other technologies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We collect similar information respecting the usage of our apps. We use this information to help us understand user activity on our websites, to provide you with content appropriate for your region, and to monitor and improve our websites.

Cookies: Our websites use a technology called “cookies”. A cookie is a small text file stored on your device that identifies your browser/device/IP address – but not you as an individual – to our computers each time you visit one of our websites. More information about cookies can be found at www.en.wikipedia.org/wiki/HTTP_cookie

We use cookies on the pages on our websites where you are prompted to log in or that are customizable. If you have registered with our websites, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize our websites in accordance with your preferences and interests. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies (these controls are typically found in the privacy settings for your browser). You do not need to enable cookies to visit our websites; however, if you decide not to accept cookies when visiting one of our websites, you may not be able to take advantage of all of the features of that site.

Tracer Tags & Web Beacons: Our websites may also use a technology called “tracer tags” or “Web Beacons”. A web beacon is a small transparent graphic image that allows us to record simple user actions related to our websites, marketing, and/or email communications received from us, to help us determine the usage and effectiveness of our site and communications. These “images” are automatically loaded to your browser/device when you visit the website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. This technology allows us to understand which pages you visit on our websites. These tracer tags work together with cookies and are used to help us optimize and tailor our websites and communications for you and future visitors. Disabling cookies will also disable any web beacons from receiving data.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the website(s), and the quality of leads. For more information or to opt-out, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.

 

Interest-Based Advertising

General

We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our websites and apps and other websites and apps in order to provide you with tailored advertisements on our behalf on third party websites across the Internet. These companies may collect information about your activity across your different devices on our websites and apps and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites and apps. This information may also be used to evaluate our online advertising campaigns.

For more information about interest-based advertising on your desktop or mobile browser and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the DAAC, please visit the Digital Advertising Alliance of Canada website. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC’s AppChoices tool, please download the version of AppChoices for your device. Ad Choices opt out tool.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes, including to produce aggregated website analytics, and you may still see ads from us; however, the ads will not be targeted based on behavioural information about you, and may therefore be less relevant to you and your interests.

To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to a particular web browser you have used, so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.

 

Social Media Advertising

We may also use services provided by third-party platforms (such as social networking platforms, search engines and other third-party websites) to serve demographically-targeted advertisements on such platforms to users of those platforms, based on user data collected by the operators of those platforms. Generally, your receipt of advertising on such platforms is governed by the privacy policy, terms of use, and preference options provided by the provider of the platform in question.

From time to time, we may also engage third-party platforms to serve users of those platforms with more individually-targeted advertising, which is based both on the platform’s user data and your interactions with Longo’s outside of the platform. To do this, we provide to the platform provider a “hashed version” of your email address or other potentially connecting information, which could be matched to your profile with that platform. Hashing is a mathematical operation that applies an equation to information so as to produce an encrypted value that cannot be reversed to reveal the original data. Both Longo’s and the platform run the same one-way hash function on the same data element, for an example, an email address. As a result, when Longo’s provides the platform with the hashed email addresses of a selected group of Guests, the platform is able to match the hashed value against the corresponding hashed value for users of the platform, allowing the platform to target Longo’s Guests that are users of that platform with relevant advertising, based on demographic and other factors selected by Longo’s. Longo’s provides only the hashed value and no other information about you to the platform. Further information about this process may be provided by the social media platforms that you use (see, for example, the “ads” icon in Facebook’s user Privacy Settings and Tools), and you may exercise the preferences provided by those social media platforms with respect to your viewing of advertising on those platforms. To opt-out of the use by Longo’s of the Personal Information we hold about you for such purposes, please see Your Options.

 

Retention

Longo’s will only retain Personal Information to the extent necessary for the purposes identified in this Privacy Commitment, or to which you might otherwise consent, after which your Personal Information will be securely destroyed or irreversibly erased or de-identified. Personal Information may be stored “in the cloud” or otherwise outside of Canada, where it may be subject to the legal regime of the jurisdiction in which it is stored.

As noted below, under Your Options, you may cancel your membership in a Program or otherwise request deletion of your Personal Information. Note that, in some cases, Longo’s may retain some of your Personal Information for a reasonable period of time for legal, administrative or compliance purposes.

 

Security

Longo’s has established appropriate technological, physical and contractual security measures designed to help protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information.

 

Your Options

Longo’s provides you with a number of options through which you may exercise certain preferences with respect to our use of your Personal Information, obtain access to the Personal Information that we hold about you, or request revisions to or deletion of that information.

 

Opting Out

You may generally withdraw your consent to our use or disclosure of your Personal Information at any time, subject to legal and contractual restrictions; however, without such consent, we may be unable to provide you with certain services or benefits. For example, if you withdraw your consent for the use of your Personal Information for the purposes of earning points or other benefits under a Program, you will no longer be able to participate in that Program.

 

a. Direct Marketing

From time to time, with your consent or as otherwise permitted by law, we may use Personal Information to communicate with Guests regarding promotions, contests, offers, incentives, rewards, surveys, questionnaires and other pertinent matters such as products and services, as described under Purposes, above.

If you would prefer not to receive such communications from us, you may opt-out at any time by contacting Longo’s at the addresses provided under “Contact Us”. If you receive promotional email messages from us, you may also unsubscribe from such messages by using the unsubscribe mechanism found in all such messages. Opting out from the receipt of direct marketing material will not affect your privileges or ability to participate in a Program, nor will it prevent the provision of periodic statements to you with respect to any point or similar balances in a Program.

 

b. Interest-Based Advertising

As described above, under Interest-Based Advertising, you may opt-out of receiving online behavioural advertising from third party advertising companies who collect data on our websites by visiting the Digital Advertising Alliance of Canada website.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads on many of the Internet sites that you visit; however, these ads will not be targeted based on your perceived interests and tastes, and may therefore be less relevant to you.

As also described above, you may opt-out of having Longo’s using the Personal Information it holds about you to target ads to you when you are on social media platforms.

 

Access and Correction

Upon request, Guests may examine the Personal Information about them that Longo’s holds, except as provided by law. Where Longo’s is unable to provide access to all the Personal Information it holds about you, it will provide the reasons why it is unable to do so. Where Longo’s receives a request from a Guest to examine Personal Information collected and retained, Longo’s will respond to the request within 30 business days.

You may request access to your Personal Information by making a request, in writing, to Longo’s Privacy Officer, at the addresses provided under Contact Us. Note that, in an effort to prevent fraudulent or unauthorized requests for access, we may request identification for authentication purposes.

You may also make a subsequent request to the Longo’s Privacy Officer to correct any Personal Information that you feel is inaccurate or incomplete. You may also request the deletion of your Personal Information, subject to legal and contractual restrictions; however, please note that deletion of some information may impact our ability to provide you with certain services.

 

Changes and Updates

Longo’s may revise this Privacy Commitment from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Commitment we will revise the “last updated” date at the top of the Commitment. You should check back here periodically to find out if any changes have been made. If we make substantial changes we will, as appropriate, prominently post these changes to our website or notify registered Guests directly.

If you disagree with any change to the Privacy Commitment, you may close your account and refrain from using our services, or in some cases, by opting out. Continuing to use our services, including our websites, after we post or communicate a change signifies that you consent to the revised terms of the Privacy Commitment.

On occasion, we may also identify new purposes for the collection or use of Personal Information, such as in connection with a new promotion or Program. We will describe such uses in separate notices or other communications.

Should you have any questions about this Privacy Commitment, or the manner in which Longo’s collects, uses, shares and protects your Personal Information, you may write to our Privacy Officer at the postal or email addresses provided below .

 

Contact Us

If you would like to opt-out of any uses of your Personal Information, obtain access, request correction or deletion, make a complaint, or generally have any questions or concerns about our Privacy Commitment, you may contact the Longo’s Privacy Officer at the address provided below.

Longo’s Privacy Officer: 8800 Huntington Road, Vaughan, Ontario, L4H 3M6

Email: privacy@longos.com

Longo’s will consider all complaints, and will respond within 30 business days after receipt of written complaint. If the complaint is well-founded, Longo’s will take suitable measures to address the complaint.

Copies of this Privacy Commitment may be obtained at any time by request directed to the Longo’s Privacy Officer. This Privacy Commitment is also available on Program websites.

 

Longo’s Accessibility Policy

Statement of Commitment

Longo Brothers Fruit Markets Inc. (Longo’s) has partnered with eSSENTIAL Accessibility to make its web content accessible as part of its online inclusion efforts. We are actively working to improve the accessibility and usability of our website and adhere to many of the available standards and guidelines.

Our goal is to ensure that everyone has access to information on our website and can fully interact without barriers. We are currently working on http://longos.com to identify potential accessibility issues and ensure that we are striving to improve the usability of the site for people of all abilities. Measures have been taken to ensure that we follow best practices as put forth by the World Wide Web Consortium’s (W3C’s) Web Content Accessibility Guidelines (WCAG) 2.0 Level A & AA under AODA. 

Additionally, we provide an Assistive Technology app featured on our website for customers who have trouble typing, gesturing, moving a mouse or reading. The app incorporates tools such as mouse and keyboard replacements, voice recognition, speech enablement, hands-free/touch-free navigation and more that empower the customer to overcome their challenges and access the Longo’s website with ease.
If you have difficulty accessing our website, or if you have feedback on how we can improve your online experience, please contact us, we'd be happy to help!

 

Policy Guidelines

Longo’s will strive to ensure that its policies, practices and procedures are consistent with the following our core principles of treating all persons with mutual respect which also includes but is not limited to:
· Dignity
· Independence
· Integration
· Equal Opportunity

 

Longo's Accessibility Service Provision

See Longo’s Accessibility Service Provision Policy

 

Accessibility Policy and Plan

Longo’s has developed, implemented and published an Accessibility Policy and multi-year Accessibility plan which documents Longo’s commitment to meet the accessibility needs of persons with disabilities in a timely manner.

 

Accessible Point-of-Sales Programs and Devices

When procuring or acquiring point-of-sales programs and devices, Longo’s will endeavour to incorporate accessibility criteria and features where feasible.

 

Training

Longo’s will provide training to all team members on the requirements of the accessibility standards under the AODA and on the Human Rights Code as it pertains to persons with disabilities.

 

Information and Communication Supports

Longo’s will review their existing process for receiving and responding to feedback to ensure that our methods are accessible to persons with disabilities and to make any changes required to ensure fair and equal treatment for everyone.
Longo’s will provide or arrange for accessible formats and communications supports when requested by person(s) with disabilities.
Longo’s will ensure that where practicable, all of its new and existing websites and web content shall conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 standards.

 

Employment Standards

In keeping with Longo’s belief of integration and equal opportunity for everyone, Longo’s is committed to provide equal employment opportunities, including to persons with disabilities.

 

Design of Public Spaces

Longo’s will comply with the AODA Design of Public Spaces Standards when undertaking new construction and redevelopment of public spaces in the following areas:
Exterior paths of travel · Accessible parking · Obtaining services · Maintenance